Privacy

Sentio customer privacy notice

This privacy notice tells you what to expect us to do with your personal information.

Contact details

Email: hello@sentio.agency

What information we collect, use, and why

We collect or use the following information to provide and improve products and services for clients:

• Names and contact details
• Occupation
• Payment details (including card or bank information for transfers and direct debits)
• Usage data (including information about how you interact with and use our website, products and services)
• Health information (such as medical records or health conditions)
• Information relating to compliments or complaints
• Video recordings
• Audio recordings (eg calls)
• Records of meetings and decisions
• Website user information

We also collect or use the following special category information to provide and improve products and services for clients. This information is subject to additional protection due to its sensitive nature:

• Racial or ethnic origin
• Religious or philosophical beliefs
• Genetic information
• Health information
• Sex life information
• Sexual orientation information

We collect or use the following personal information for information updates or marketing purposes:

• Names and contact details
• Profile information
• Marketing preferences

We collect or use the following personal information to comply with legal requirements:

• Name
• Contact information
• Any other personal information required to comply with legal obligations

We collect or use the following personal information for recruitment purposes:

• Contact details (eg name, address, telephone number or personal email address)
• Employment history (eg job application, employment references or secondary employment)
• Education history (eg qualifications)
• Right to work information

We also collect or use the following special category information for recruitment purposes. This information is subject to additional protection due to its sensitive nature:

• Racial or ethnic origin
• Religious or philosophical beliefs
• Health information
• Sexual orientation information

We collect or use the following personal information for dealing with queries, complaints or claims:

• Names and contact details
• Purchase or service history
• Customer or client accounts and records
• Correspondence

We also collect or use the following special category information for dealing with queries, complaints or claims. This information is subject to additional protection due to its sensitive nature:

• Racial or ethnic origin
• Religious or philosophical beliefs
• Health information
• Sex life information
• Sexual orientation information

Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

• Your right of access: You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for.
• Your right to rectification: You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete.
• Your right to erasure: You have the right to ask us to delete your personal information.
• Your right to restriction of processing: You have the right to ask us to limit how we can use your personal information.
• Your right to object to processing: You have the right to object to the processing of your personal data.
• Your right to data portability: You have the right to ask that we transfer the personal information you gave us to another organisation, or to you.
• Your right to withdraw consent: When we use consent as our lawful basis you have the right to withdraw your consent at any time.

If you make a request, we must respond to you without undue delay and in any event within one month. To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information to provide and improve products and services for clients are:

• Consent: we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract: we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
• Legitimate interests: we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are: We have a legitimate interest in processing personal information where necessary to provide, manage and improve our healthcare market research, commercial insight and advisory services. This includes communicating with clients and research partners, planning and administering projects, selecting appropriate participants, maintaining accurate business records, improving our methodologies and service quality, and protecting our commercial and legal interests. This processing benefits Sentio, its clients and research participants by enabling projects to be delivered efficiently, accurately and securely. We limit the information used to what is reasonably necessary, restrict access, apply appropriate confidentiality and security measures, and consider whether individuals would reasonably expect the processing. We do not rely on legitimate interests where the individual’s rights and freedoms outweigh our interests, and individuals may object to relevant processing.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

Our lawful bases for collecting or using personal information for information updates or marketing purposes are:

• Consent: we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Legitimate interests: We have a legitimate interest in using professional contact information to promote Sentio’s healthcare market research and advisory services to organisations and individuals whose roles are likely to make those services relevant. This includes contacting pharmaceutical, biotechnology, healthcare investment and professional-services contacts about potential projects, partnerships, research initiatives and relevant service updates. We limit this activity to proportionate business-to-business communications using professional information obtained directly, from public professional sources or from reputable business-information providers. We consider the recipient’s role, the relevance of the communication and their reasonable expectations before making contact. Each communication provides a clear way to opt out, and we stop using personal information for direct marketing where an individual objects. We do not use special-category information for marketing purposes.

Our lawful bases for collecting or using personal information to comply with legal requirements:

• Legal obligation: we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Our lawful bases for collecting or using personal information for recruitment purposes are:

• Contract: we have to collect or use the information so we can enter into or carry out a contract with you.
• Legal obligation: we have to collect or use your information so we can comply with the law.
• Legitimate interests: We have a legitimate interest in processing candidate information to assess suitability for roles, manage recruitment exercises, communicate with applicants, verify information provided, maintain appropriate recruitment records and protect Sentio against potential legal claims. This processing enables us to recruit appropriately qualified employees, contractors and consultants and to operate an efficient and fair selection process. We limit the information collected to what is relevant for the role, restrict access to those involved in recruitment, retain it only for an appropriate period and consider the candidate’s reasonable expectations and rights. We do not rely on legitimate interests where those rights outweigh our interests.

Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:

• Contract: we have to collect or use the information so we can enter into or carry out a contract with you.
• Legal obligation: we have to collect or use your information so we can comply with the law.
• Legitimate interests: We have a legitimate interest in processing personal information to respond to enquiries, investigate and resolve complaints, maintain appropriate records, manage disputes and establish, exercise or defend legal claims. This processing benefits both Sentio and the individuals involved by enabling matters to be handled accurately, fairly and efficiently. We limit processing to information relevant to the issue, restrict access to those who need it, apply appropriate confidentiality and security measures, and retain records only for as long as reasonably necessary. We do not rely on legitimate interests where an individual’s rights and freedoms outweigh our interests.

Where we get personal information from

• Directly from you
• Regulatory authorities
• Publicly available sources
• Previous employment
• Market research organisations
• Providers of marketing lists and other personal information
• Suppliers and service providers
• Third parties: We may receive personal information from clients, research recruitment partners, panel providers, professional advisers, suppliers, contractors and other organisations involved in delivering or supporting our services. This may include professional contact details, participant information, project-related records, recruitment information and correspondence. Where information is obtained indirectly, we use it only for relevant and lawful purposes and provide appropriate privacy information where required.

How long we keep information

We retain personal information only for as long as reasonably necessary for the purpose for which it was collected, including legal, regulatory, contractual and accounting requirements.

Unless a longer period is required for a particular project or by law, we generally apply the following periods:

• Website enquiries and general correspondence: up to 24 months after the last substantive interaction.
• Business development and professional contact information: until the person objects, opts out or the information is no longer relevant, subject to periodic review.
• Client, supplier and project administration records: up to six years after the relevant relationship or project ends.
• Research participant contact and screening information: for the period stated in the project-specific participant privacy notice.
• Research recordings and identifiable transcripts: for the period agreed with the client and stated to participants, after which they are deleted, anonymised or securely archived where lawful.
• Recruitment records for unsuccessful candidates: normally up to six months after the recruitment process ends, unless the candidate agrees to a longer period.
• Financial, contractual and tax records: normally six years, or longer where required by law.
• Marketing suppression records: retained as necessary to ensure that people who have opted out are not contacted again.

We may retain information for longer where necessary to establish, exercise or defend legal claims, comply with a legal obligation or respond to a regulatory investigation. We review retained information periodically and securely delete or anonymise it when it is no longer required.

Who we share information with

Sentio does not currently have any standing joint-controller arrangements.

For individual research projects, Sentio and a client or research partner may jointly determine certain purposes and methods of processing personal information. Where this occurs, the parties will document their respective responsibilities and provide affected individuals with project-specific information explaining the arrangement and how they can exercise their rights.

Data processors

Cloud, email, storage, CRM, marketing, survey, interview, transcription, translation, accounting, payment, analytics and technical service providers may store, organise, transmit or otherwise process personal information on our behalf to support website operation, communications, project management, research recruitment and fieldwork, surveys and interviews, transcription and translation, secure document storage, payments, accounting and business administration. They may process information only for the contracted service and subject to applicable data-protection and confidentiality requirements.

Others we share personal information with

• Professional or legal advisors
• External auditors
• Organisations we’re legally obliged to share personal information with
• Suppliers and service providers
• Professional consultants
• Clients may receive research findings and project information. Recruitment and panel providers may receive details needed to recruit participants. Research partners may receive information needed to deliver the project. Information may be identifiable, pseudonymised or anonymised, depending on the project and participant notice.

Sharing information outside the UK

Where necessary, we may transfer personal information outside of the UK. When doing so, we comply with the UK GDPR, making sure appropriate safeguards are in place. For further information or to obtain a copy of the appropriate safeguard for any of the transfers below, please contact us using the contact information provided above.

Where necessary, our data processors will share personal information outside of the UK. When doing so, they comply with the UK GDPR, making sure appropriate safeguards are in place.

How to complain

If you have any concerns about our use of your personal information, you can make a data protection complaint to us at hello@sentio.agency.

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

Information Commissioner’s Office
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Helpline: 0303 123 1113
ico.org.uk/make-a-complaint